Not legal advice. We provide education and training, not legal advice. Nothing on this website, in our courses, or in our materials is legal advice or creates an attorney-client relationship. Consult a qualified attorney about your own situation.
Effective date: November 5, 2026
1. Who we are
This website and our learning platform are operated by C. Douglas & Associates, Inc., doing business as Inclusion Learning Lab and AI Governance for HR ("we," "us"). We are the controller of the personal data described here.
C. Douglas & Associates, Inc.
P.O. Box 211835, West Palm Beach, FL 33421
Phone: 561-795-3036
Email: [email protected]
This policy covers our main website, our Thinkific-hosted learning platform, our courses, coaching, enterprise programs, and our marketing communications. Our newsletter on Substack is covered by Substack's privacy policy and a separate notice of ours.
2. Information we collect
Information you give us. Name, email, phone, job title, organization, billing details, shipping address (for book orders), course submissions, assessment responses, messages, recordings of live group sessions you join, and anything you share in coaching or support conversations.
Information collected automatically. Course progress and completion, login activity, IP address, device and browser type, pages viewed, and cookie data (see Section 5).
Information from other sources. We may receive professional contact details (name, title, employer, business email) from business databases, professional networks such as LinkedIn, public company websites, and email verification services. We use this to reach professionals whose roles relate to our programs. When we obtain your information this way, we will tell you the source on request.
We do not knowingly collect sensitive personal data (such as health, religion, or biometric data). Please do not include it in course submissions.
3. How we use it, and our legal basis
The legal basis column applies where EU or UK data protection law governs our processing.
| Purpose | Legal basis |
|---|---|
| Deliver courses, coaching, certificates and enterprise programs | Performance of a contract |
| Process payments, renewals and refunds | Performance of a contract; legal obligation (tax records) |
| Account support and service messages | Performance of a contract |
| Send newsletters and marketing to people who opted in | Consent (withdraw anytime) |
| Contact professionals about relevant programs (business outreach) | Legitimate interest, with an opt-out in every message |
| Show ads to matched audiences on LinkedIn | Legitimate interest or consent, as local law requires |
| Improve our courses and website | Legitimate interest |
| Prevent fraud and secure our systems | Legitimate interest; legal obligation |
| Comply with law and respond to lawful requests | Legal obligation |
Where we rely on legitimate interest, we have weighed our interest against your rights. You may object at any time (Section 6).
4. Who we share it with
We do not sell personal data. We share it only with service providers that help us operate, under contracts that limit their use of it.
| Provider type | Examples | Purpose |
|---|---|---|
| Learning platform | Thinkific | Hosts our website, courses, accounts and checkout |
| Payment processing | Stripe; Thinkific's payment processors | Process payments and renewals; calculate sales tax |
| Book printing and shipping | IngramSpark | Print and ship book orders to the address you provide |
| CRM and email | HubSpot, ActiveCampaign | Manage contacts and send email |
| Outreach and verification | Smartlead, ZeroBounce | Send business outreach; verify email validity |
| Advertising | Match contact lists to show ads to professionals | |
| Professional advisers | Accountants, attorneys | Legal, tax and audit needs |
LinkedIn ad matching. We may upload contact details to LinkedIn so our ads reach people who may be interested. Some U.S. state laws treat this as "sharing" for targeted advertising. To opt out, email [email protected].
We may also disclose data when required by law, to protect rights and safety, or as part of a merger, acquisition or sale of assets. Enterprise clients may receive learner completion and progress data for their own enrolled employees.
5. Cookies, retention, security and transfers
Cookies. Our platform, Thinkific, sets essential cookies needed for login, checkout and course progress. We may also use analytics and advertising tags (such as the LinkedIn Insight Tag). Where the law requires consent, we ask before setting non-essential cookies, and you can change your choice at any time. You can also block cookies in your browser, though parts of the site may not work. Thinkific's own cookie practices are described in its privacy policy.
How long we keep data.
| Data | Retention |
|---|---|
| Website, cookie and technical log data | 90 days |
| Account and course records | While your account is active, plus 3 years for certificate verification |
| Payment and tax records | 7 years, as required for tax and accounting |
| Marketing contacts | Until you unsubscribe or object, or after 24 months with no engagement |
| Support messages | 2 years |
Security. We use administrative, technical and physical safeguards, including access controls and reputable hosted platforms. No system is perfectly secure. If a breach affects your data, we will notify you as required by law.
International transfers. We are based in the United States, and our providers may process data in the U.S. and elsewhere. Where EU or UK law applies, we rely on recognized safeguards such as the EU-U.S. Data Privacy Framework or Standard Contractual Clauses.
6. Your rights
Wherever you live, you may ask us to access, correct, or delete your personal data, and to stop marketing to you. Depending on your location (for example, the EU, UK, or certain U.S. states), you may also have rights to data portability, to restrict or object to processing, to withdraw consent, and to opt out of targeted advertising. We will not discriminate against you for using these rights.
How to make a request. Email [email protected] or call 561-795-3036. We will verify your identity before acting, respond within 30 days, and tell you if we need more time. An authorized agent may act for you with written permission. If we decline your request, you may appeal by replying to our decision, and we will respond within 45 days. EU and UK residents may also complain to their local data protection authority.
Unsubscribing. Every marketing email includes an unsubscribe link.
7. Our use of AI
We use AI tools to help draft content and run our operations, with human review of everything we publish. We do not use your course submissions or personal data to train AI models. We do not make decisions about you that have legal or similarly significant effects using automated processing alone.
8. Children
Our services are for adults 18 and older. We do not knowingly collect data from anyone under 18. If you believe we have, contact us and we will delete it.
9. Changes
We will post updates here with a new effective date. For material changes, we will notify active account holders by email.
10. Contact
C. Douglas & Associates, Inc., d/b/a Inclusion Learning Lab and AI Governance for HR · P.O. Box 211835, West Palm Beach, FL 33421 · 561-795-3036 · [email protected]